Whistle- Blowing Policy

1. Definition

Whistle blowing is a specific means by which an employee or stakeholder can report and disclose through established channels, concerns about unethical behaviour, malpractices, illegal acts or failure to comply with regulatory requirements that is taking place / has taken place / may take place in the future.

2. Objectives

The main objectives of the Policy are:

To provide an avenue for employees and stakeholders to raise their concern in good faith on a confidential basis;

To ensure that all allegations are thoroughly investigated for appropriate action;

To safeguard the individual who made the concern or reported the misconduct (“the whistle-blower”);

To establish new measure or process to prevent the occurrence of the similar situation, where necessary

Be committed to develop a culture of openness, accountability and integrity; and

To strengthen corporate governance processes and practices

3. Scope

This Policy applies to all Directors and employees of the Group, including full time, part time and contract employees and outside parties such as vendors, clients, contractors and other stakeholders. This Policy governs the reporting and investigation of improper or illegal activities as well as the protection offered to the whistle-blower who act in good faith.

4. Procedures

In general, work related issues should be discussed and resolved with the immediate superior, Human Resource Department and with the Departmental Head, if required.

If the concern remains unresolved or it is believe that it is not possible or appropriate, the concern should be addressed and reported to the Group Chief Executive Officer (“CEO”) or the Chairman of the Company.

An employee can report the issue by email or by mail (marked “strictly confidential”) addressing directly to the CEO with full contact information including the company and the department he/she works, the genuine name, address and contact number. The mailing address is:

Only genuine concerns raised to the CEO will be taken seriously and the confidentiality of the employee raising concern will be protected. The CEO or his designated personnel will conduct an investigation by discussion with the relevant employees, seeking and establishing the facts.

The employee raising concern will be updated of the outcome of the investigation.

If the employee is not satisfied with the decision made by the CEO or in the case where reporting to Management is a concern, he/she can escalate his/her report to the Chairman of the Audit Committee in a sealed envelope (marked “To be opened by the Chairman of the Audit Committee only”) to:

The Chairman of the Audit Committee will deliberate the case with his Committee members and decide on the appropriate course of action. A written reply shall then be issued by the Chairman of the Audit Committee.

If deems appropriate, the Chairman of the Audit Committee shall report the case to the Board for further action.

5. Reporting

The written report of the conclusion of all cases shall be properly documented. The report shall be made available upon request by any members of the Audit Committee.

6. Review Of The Policy

This Policy shall be reviewed annually by the Audit Committee. Revisions, amendments and alterations to this Policy can only be implemented with the approval of the Board of Directors.